“One Big Beautiful Bill” & International Tax: What CPAs Need to Know

Host Tim LeMasters and guest Jason Rauhe, CPA, dive into the complexities of the new One Big, Beautiful Bill (OB3) and its shifts in US international tax law.

The One Big Beautiful Bill (OBBB) replaces the GILTI regime with Net CFC Tested Income, dramatically changing how U.S. shareholders are taxed on foreign earnings. With the repeal of QBAI and interest deductions, CPAs and multinational businesses must revisit their international tax strategies to avoid surprises under the new rules.

Mexico’s Tax Administration Service (SAT) has dramatically increased Transfer Pricing enforcement, collecting over 106 billion pesos from multinational corporations between 2019 and 2024. With stricter documentation requirements and a specialized audit department, companies must reassess their compliance strategies to avoid costly adjustments.

As manufacturers expand internationally, they face a complex web of tax considerations—ranging from transfer pricing and tariffs to global entity structuring and minimum tax rules.

The IRS has posted updated Filing Requirement Exceptions for Schedule K-2 and K-3 as of June 4, 2025. Although these changes were posted in 2025, they are retroactive to the 2024 tax year.

Host ⁠Jerry Hammel, CPA,⁠ is joined by ⁠Greg Lambrecht, CPA⁠, and ⁠Jason Rauhe, CPA⁠, for a timely discussion on the future of international tax planning as we approach the potential sunset of the Tax Cuts and Jobs Act (TCJA).

The U.S. dropped its proposed Section 899 tax after a G7 deal eased global tax tensions for American businesses.

The Senate’s “One Big Beautiful Bill” proposes major international tax changes, creating both planning opportunities and compliance challenges for CPAs advising global clients.

Think forgetting to file an FBAR is no big deal? One taxpayer just got hit with $3.24 million in penalties. Find out how it happened—and how to avoid the same fate.

The IRS has released updates to Rev. Proc. 2025-23, refining the list of accounting method changes eligible for automatic approval. These changes streamline guidance in several areas but introduce new limitations for international tax adjustments that global teams should review closely.